This case sorts out the statute of limitations issues when there is a real denial of a claim after a deemed denial. The basic rule is that you cannot file in court until the agency actually rules on your claim and sends you notice of the ruling, or until six months after initial filing if the agency does not act. The twist is that there is no tolling of the SOL in a deemed denied claim - the plaintiff can file any time in the future. If, however, at some point after the 6 months deemed denied period, the agency issues a real denial and notice, a separate provision in the law starts a 6 month SOL running. In this case, the plaintiff filed too early on a deemed denied claim, and while that was pending, there was a real denial by the agency. The deemed denied claim was dismissed, and the plaintiff did not refile until more than six months after the real denial. After a good analysis of the provisions, the court found that new claim was barred. This issue is currently before the United States Supreme Court, so there may be definitive law on potential equitable tolling by the end of the 2014-2015 term.